Thank you.
Good morning, Mr. Chair and members of the committee.
My name is Imran Qayyum and I'm the chair of the Canadian Migration Institute, which I will refer to as CMI. The role of CMI is to provide a platform for authorized immigration representatives who work collaboratively to enhance their profession.
The Canadian Migration Institute came into existence in September 2007, and we currently represent over 1,500 fellows, all of whom are authorized immigration representatives belonging to the immigration consulting, legal, and Quebec notary professions. These fellows practice throughout Canada and overseas.
CMI's mandate is to educate, accredit, advocate, and act as a policy research body on behalf of fellows. As the largest professional organization of its kind in North America, we're honoured to be here today in order to share our views on the subject of processing times related to the family class and investor class of immigrants.
Let me start by sharing some of our observations on the family class, which for the purposes of today's submission we've divided up into two main categories: spousal or partner applications, which I will refer to as FC1; and parent or grandparent applications, which I will refer to as FC4.
As the committee knows, all family class cases are initiated in Canada when the application is submitted to the case processing centre in Mississauga, commonly known as CPC Mississauga. The case processing centre confirms whether or not the sponsor, who is sponsoring his or her close family relative, meets the legislative requirements to do so. In the case of FC1-type applications, this process takes between one to two months, whereas in the case of FC4-type applications, this process is taking between 32 to 36 months. Once the case processing centre in Mississauga accepts the sponsorship and confirms the eligibility of the sponsor, the application is forwarded to an overseas visa processing post or to the MICC, as in the case of sponsors residing in the province of Quebec.
In today's submission I'll be referring to statistics that were obtained through access to information requests made by Lexbase for FC1 and FC4 cases for the period of April 2008 to March 2009. These statistics show that during the 12-month period in question, overseas visa posts completed approximately 40,000 FC1 cases. 80% of these cases were completed within 11 months or less. During the same period, approximately 9,800 FC4 cases were completed; 80% of these cases were completed within 20 months or less.
Given that one of the objectives of the Immigration and Refugee Protection Act is to see that family members are reunited in Canada, CMI is concerned that these processing times run contrary to the spirit of the family reunification objective of IRPA. We believe more can be done, especially in the FC4 category.
Some of CMI's recommendations to address these issues are as follows.
First, we would recommend that the government allocate more resources to FC4 processing.
Second, we would recommend the perfected application for FC4 cases, wherein sponsorship forms as well as the immigrant forms and supporting documents are submitted to CPC Mississauga, as is the case for FC1-type applications.
Last, we would encourage CPC Mississauga to use electronic communications with the sponsor or their authorized representative as often as possible when acknowledging receipt of sponsorship applications or requesting additional information or supporting documentation. Leveraging electronic communication would certainly alleviate some of the current pressures contributing to lengthy processing times.
I would now like to turn your attention to CMI's views on the investor class processing times. For today's submission, I will be making reference to statistics obtained through access to information requests made by HSBC for the period of January 2009 to August 2009.
As of August 2009, the global inventory for investor class cases was more than 11,000. Given that each case requires, at minimum, an investment of $400,000 in Canada, this inventory represents a potential of $4.4 billion in available dormant and virtually zero-cost stimulus capital that could be flowing to Canada to fund infrastructure projects to stimulate the economy.
The current annual target set by Citizenship and Immigration Canada for investor class cases is 2,155. It is worth noting that the current annual target of 2,155 represents final dispositions, or FDs. These numbers include refused or withdrawn applications, not just approved cases.
For example, from January until August 31, 2009, of the 1,697 final dispositions, approximately 50% were approved cases, 25% were refused cases, and 25% were applications withdrawn by the investors themselves, who were largely frustrated by the long processing delays. If extrapolated and applied to the current inventory of cases in process, this 25% withdrawal rate represents a potential $1 billion of zero-cost stimulus capital that Canada will never benefit from.
According to our calculations, the current inventory of 11,000-plus investor applications at an annual target of approximately 2,000 represents a global average processing time of more than five years. This year to date, over 4,000 new applications have been received, representing double the current annual processing target. With new application intake rates at this level, we believe processing times for investors will continue to grow as inventories balloon.
By definition, investor applicants are successful, high-networked individuals with business experience willing to invest $400,000 of their capital for five years to be used by participating provinces for infrastructure and other economic priorities. Lengthy processing times represent a clear discouragement to such applicants and will encourage withdrawals of applications as these highly desirable immigrants turn to other, more attractive options available to them globally.
Nor is the economic impact of these individuals and their families limited to their $400,000 qualifying investment. These individuals represent a significant potential additional positive economic impact as they and their families establish in Canada and buy homes, cars, and furniture, and make other investments for their future in Canada.
Measures must be introduced that will shorten processing times in order not to miss the opportunity to quickly flow desperately needed zero-cost capital to provincial governments, who in turn can use it for much-needed infrastructure projects and related stimulus spending.
Once again, the current inventory represents over $4.4 billion in available potential capital. This statement bears repeating because it is so important.
Some of CMI's recommendations to address these issues are as follows. First, we recommend increasing the annual target for federal and investor applications to 5,000 FDs per year, which will have an immediate impact on reducing processing times. The federal immigrant investor program already appears to be losing significant market share to the Quebec immigrant investor program, which underwent changes to make the Quebec program more attractive in February 2009. Quebec has established an ambitious target for 2009 of 2,004 actual approvals and investments, not final dispositions. It's important to understand the difference.
Quebec processing times are generally much better than federal processing times, and recognizing the importance of this investment capital during these tough economic times, the Quebec trend is toward faster decision-making.
CMI would suggest the need to balance the interest of all Canadian provinces and territories and the benefits they receive individually through immigration necessitates a substantial increase in the annual federal investor processing targets.
Second, CMI would recommend establishing a centralized intake office, or CIO, for investor applicants in Canada. The establishment of a CIO would allow for more training and specialization for reviewing officers related to business cases, centralized and coordinated management of applications, and increased program security and integrity. This recommendation would also result in additional employment opportunities for Canadians. Given that 85% of federal investor cases are assessed without the need for an interview, adopting a CIO at the front end and reviewing investor cases would make it possible to address such issues as identity, available funds, qualifying business experience, and source of funds.
CMI suggests CIC establish at such a CIO an eligibility requirement step for investors, similar to the federal skilled worker program. This would be separated from the processing under the regulations. This would also remove the current investors simplified application process, which many believe is a significant cause of the current processing delays.
